Financialreportingdevelopments Bb1883 Realestateprojectcosts July2011

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    Financial reportingdevelopments

    A comprehensive guide

    Financial reporting

    developments

    Real estate project

    costsRevised July 2011

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    Financial reporting developments -Real estate project costs

    To our clients and other friends

    The guidance for real estate project costs primarily addresses whether costs associated with acquiring,developing, constructing, selling, or renting real estate projects (other than real estate projects

    developed for an entitys own use) should be capitalized or charged to expense as incurred. While the

    guidance for real estate project costs (formerly Statement 67) was originally issued more than 25 years

    ago, determining what costs to capitalize, when to capitalize them and accounting for subsequent

    measurement considerations (including impairment considerations and accounting for abandoned

    property) continues to be challenging.

    We hope this publication will help you understand and successfully apply the guidance for real estate

    project costs. Ernst & Young professionals are prepared to assist you in your understanding and are

    ready to discuss your particular concerns and questions.

    July 2011

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    Financial reporting developments -Real estate project costs

    Contents

    1

    Introduction and scope ............................................................................................... 1.1 General ................................................................................................................................

    2 Real estate acquisition, development and construction costs .......................................

    2.1 Preacquisition costs ..............................................................................................................

    2.1.1 Accounting for internal costs relating to real estate property acquisitions .......................

    2.2 Taxes and insurance .............................................................................................................

    2.2.1 Accounting for special assessments and tax increment financing entities ........................

    2.2.2 Rental costs incurred during a construction period ........................................................ 1

    2.2.3 Interest ...................................................................................................................... 1

    2.3 Project costs ....................................................................................................................... 1

    2.3.1 Accounting for asset retirement obligations, the costs of asbestos

    removal, and costs to treat environmental contamination ............................................. 1

    2.3.2 Accounting for demolition costs ................................................................................... 1

    2.4 Amenities ............................................................................................................................ 1

    2.5 Incidental operations ............................................................................................................ 1

    2.6 Allocation of capitalized costs to the components of a real estate project ................................ 2

    2.7 Revisions of estimates.......................................................................................................... 2

    2.8 Abandonments .................................................................................................................... 2

    2.9 Donations to municipalities ................................................................................................... 2

    2.10 Changes in use .................................................................................................................... 2

    3 Costs incurred to sell and rent real estate .................................................................... 2

    3.1 Costs incurred to sell real estate projects .............................................................................. 23.2 Costs incurred to rent real estate projects ............................................................................. 2

    3.3 Initial rental operations ........................................................................................................ 3

    4 Recoverability ......................................................................................................... 3

    A Index of ASC references in this publication ................................................................ 3

    B Abbreviations used in this publication ....................................................................... 3

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    Conte

    Financial reporting developments -Real estate project costs

    Notice to readers:

    This publication includes excerpts from and references to the FASB Accounting Standards Codification

    (the Codification or ASC). The Codification uses a hierarchy that includes Topics, Subtopics, Sections

    and Paragraphs. Each Topic includes an Overall Subtopic that generally includes pervasive guidance for

    the topic and additional Subtopics, as needed, with incremental or unique guidance. Each Subtopic

    includes Sections that in turn include numbered Paragraphs. Thus, a Codification reference includes the

    Topic (XXX), Subtopic (YY), Section (ZZ) and Paragraph (PP).

    Throughout this publication references to guidance in the codification are shown using these reference

    numbers. References are also made to certain pre-codification standards (and specific sections or

    paragraphs of pre-Codification standards) in situations in which the content being discussed is excluded

    from the Codification.

    This publication has been carefully prepared but it necessarily contains information in summary form and

    is therefore intended for general guidance only; it is not intended to be a substitute for detailed research

    or the exercise of professional judgment. The information presented in this publication should not be

    construed as legal, tax, accounting, or any other professional advice or service. Ernst & Young LLP can

    accept no responsibility for loss occasioned to any person acting or refraining from action as a result ofany material in this publication. You should consult with Ernst & Young LLP or other professional

    advisors familiar with your particular factual situation for advice concerning specific audit, tax or other

    matters before making any decisions.

    Portions of FASB publications reprinted with permission. Copyright Financial Accounting Standards Board, 401 Merritt 7, P.O.Box 5116, Norwalk, CT 06856-5116, U.S.A. Copies of complete documents are available from the FASB.

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    1 Introduction and scope

    The real estate project costs guidance in ASC 970, Real Estate

    General, addresses accounting for thecosts of real estate projects, including acquisition, development, construction, selling, and initial rental

    (up to the point of normal operations as defined) costs. The general principle in the guidance for real

    estate project costs is that if costs are directly associated with a real estate project (i.e., development,

    construction, selling, and initial rental), they are capitalized and all other costs are charged to expense a

    incurred. The guidance for real estate project costs does not address the accounting for the acquisition

    of a business. See the guidance for business combinations (ASC 805, Business Combinations) for furthe

    details.

    Excerpt from Accounting Standards CodificationReal Estate General Overall

    Overview and Background970-10-05-6

    The Real Estate Project Costs Subsections establish accounting and reporting standards for

    acquisition, development, construction, selling, and rental costs associated with real estate projects.

    They also provide guidance for the accounting for initial rental operations and criteria for determining

    when the status of a rental project changes from nonoperating to operating.

    Scope and Scope Exceptions

    970-10-15-7

    The guidance in the Real Estate Project Costs Subsections applies to all entities with productive activities

    relating to real property, excluding property used primarily in the entitys non-real estate operations.

    970-10-15-8

    The guidance in the Real Estate Project Costs Subsections does not apply to the following transactions

    and activities:

    a. Real estate developed by an entity for use in its own operations, other than for sale or rental. In

    this context, real estate developed by a member of a consolidated group for use in the operations

    of another member of the group (for example, a manufacturing facility developed by a subsidiary

    for use in its parents operations) when the property is reported in the groups consolidated

    financial statements. However, this does not include property reported in the separate financial

    statements of the entity that developed it.

    b. Initial direct costs of sales-type, operating, and other types of leases, which are defined in

    Topic 840. The accounting for initial direct costs is prescribed in that Topic.

    c. Costs directly related to manufacturing, merchandising, or service activities as distinguished from

    real estate activities.

    970-10-15-9

    Paragraphs 970-340-25-16 through 25-17, 970-340-35-2, 970-340-40-2, and 970-605-25-1

    through 25-2 do not apply to real estate rental activity in which the predominant rental period is less

    than one month.

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    1 Introduction and sco

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    970-10-15-10

    Paragraphs 970-340-25-13 through 25-15 and 970-340-40-1 do not apply to real estate time-sharing

    transactions. Topic 978 provides guidance on the accounting for those transactions.

    The accounting guidance for real estate project costs:

    Only applies to real estate developed for sale or rent, not real estate developed by an enterprise for

    its own use in its operations (e.g., a factory or warehouse)

    Does not apply to real estate developed by one member of a consolidated group for use by another

    member of the group when the property is included in the groups consolidated financial statements

    Does not apply to the costs associated with acquiring an operating property (see Section 2.1.1 for

    further detail)

    Does not apply to capitalized rental costs for real estate that is rented for less than one month at a

    time such as a hotel or parking garage that is rented on a daily or weekly basis (see Section 3.2)

    Does not apply to selling costs (see Section 3.1) related to time-sharing transactions (see ASC 978

    for further details)

    1.1 General

    Excerpt from Accounting Standards CodificationReal Estate General Overall

    Scope and Scope Exceptions

    970-10-15-11

    This Subsection specifies the accounting for the following as they relate to real estate projects:

    a. Preacquisition costs

    b. Taxes and insurance

    c. Project costs

    d. Amenities

    e. Incidental operations

    f. Allocation of capitalized costs to components of a real estate project

    g. Revisions of estimates

    h. Abandonments and changes in use

    i. Selling costs

    j. Rental costs

    k. Reductions in the carrying amounts of real estate assets prescribed by the Impairment or Disposa

    of Long-Lived Assets Subsections of Subtopic 360-10.

    Refer to Sections 2.1 4.1 for detailed guidance on the accounting for real estate project costs.

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    2 Real estate acquisition, development and

    construction costs

    In general, costs (both direct and indirect) specifically associated with a real estate project that is under

    development should be capitalized. All other costs should be charged to expense as incurred.

    2.1 Preacquisition costs

    Excerpt from Accounting Standards CodificationPreacquisition Costs

    Costs related to a property that are incurred for the express purpose of, but prior to, obtaining that

    property. Examples of preacquisition costs may be costs of surveying, zoning or traffic studies, or

    payments to obtain an option on the property.

    Real Estate General Other Assets and Deferred Costs

    Recognition

    970-340-25-3

    Payments to obtain an option to acquire real property shall be capitalized as incurred. All other costs

    related to a property that are incurred before the entity acquires the property, or before the entity

    obtains an option to acquire it, shall be capitalized if all of the following conditions are met and

    otherwise shall be charged to expense as incurred:

    a. The costs are directly identifiable with the specific property.

    b. The costs would be capitalized if the property were already acquired.

    c. Acquisition of the property or of an option to acquire the property is probable (that is, likely to

    occur). This condition requires that the prospective purchaser is actively seeking to acquire the

    property and has the ability to finance or obtain financing for the acquisition and that there is no

    indication that the property is not available for sale.

    970-340-25-4

    Capitalized preacquisition costs either:

    a. Shall be included as project costs upon the acquisition of the property

    b. To the extent not recoverable by the sale of the options, plans, and so forth, shall be charged to

    expense when it is probable that the property will not be acquired.

    Preacquisition costs are defined as costs related to a property that are incurred for the express purpose

    of, but prior to, obtaining the property.Examples of preacquisition costs include costs incurred to obtain

    an option to acquire real estate and other costs incurred prior to obtaining the property, such as: zoning

    costs, environmental or feasibility studies, legal fees, finders fees, appraisals, and project planning costs.

    Costs incurred to obtain an option to acquire real estate, either from the property owner or the holder of a

    option, should be capitalized. All costs directly identifiable with a specific property that are incurred before

    an entity acquires the property, or before the entity obtains an option to acquire the property, should be

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    capitalized if acquisition of the property, or an option to acquire the property, is probable and the costs

    would be capitalized if the property were already acquired. The specific property identified should be

    available for sale and the prospective purchaser must be actively seeking to acquire the property and

    have the ability to finance or obtain financing for the acquisition. All other costs, including general and

    administrative costs incurred during the preacquisition phase, should be charged to expense as incurred.

    Illustration 2-1: Capitalized costs not directly identifiable with a specific property

    Facts:

    Company A is committed to constructing an office building to be leased to third parties in Boston.

    Management is currently evaluating three potential sites and believes it is probable that one of these

    sites will be acquired. However, no one site is more likely to be acquired than any of the others.

    Company A has incurred $50,000 in costs to establish local real estate contacts and research zoning

    and building codes.

    Analysis:

    Although Company A believes it is probable that one of the three potential sites will be acquired,

    because it is not probable that any one site will be acquired, the costs incurred are not directlyidentifiable with a specific property that is probable of being acquired. Therefore, the $50,000 in costs

    incurred to establish local real estate contracts and research zoning and building codes should be

    charged to expense as incurred.

    In determining whether the acquisition of a property or an option to acquire the property is probable,

    companies should look to the definition of probableused in ASC 450-20, Contingencies Loss

    Contingencies. As long as it is probable that an entity will acquire a specific property or an option to

    acquire that property, preacquisition costs should be capitalized and the asset should be evaluated for

    recoverability using the guidance for the impairment of long-lived assets (ASC 360-10) , whenever

    events or changes in circumstances indicate that its carrying amount may not be recoverable.

    If an entity determines that acquisition of a property is no longer probable, no new costs should becapitalized. Additionally, the fact that it is no longer probable that the property will be acquired may be

    an indicator of impairment requiring costs previously capitalized to be evaluated for recoverability in

    accordance with the provisions of ASC 360-10. If it becomes probable that a property will not be

    acquired, all capitalized costs should be written off to the extent the costs are not recoverable through

    sale (i.e., sale of an option, plans, etc.).

    The following table summarizes these concepts:

    Likelihood of acquisition

    Capitalize new qualified

    preacquisition costs?

    Treatment of previously

    capitalized costs

    Acquisition of property or option

    is probable

    Yes Evaluate for recoverability in accordance with the

    guidance for the impairment of long-lived assets

    (ASC 360-10) if impairment indicator exists

    Acquisition of property or option

    is reasonably possible

    No Evaluate for recoverability in accordance with the

    guidance for the impairment of long-lived assets

    (ASC 360-10) if impairment indicator exists

    Probable that property will not

    be acquired

    No Write-off all costs unless recoverable through

    direct sale

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    Illustration 2-2: Evaluation of capitalized costs

    Facts:

    Company A is committed to constructing an office building in Chicago at a specified site. Company A

    has an option to acquire the site and has capitalized $50,000 in preacquisition costs to date. Company

    A has not made any noticeable progress toward acquiring the property or development approval in

    several months and no longer believes that it is probable that the property will be acquired but stillbelieves it is reasonably possible that the property will be acquired.

    Analysis:

    No new preacquisition costs should be capitalized because Company A has concluded that it is no

    longer probable that the property will be acquired. Additionally, the $50,000 in costs previously

    capitalized should be evaluated for recoverability in accordance with the guidance for the impairment

    of long-lived assets (ASC 360-10). If Company A subsequently determines it is probable that the

    property will not be acquired, all capitalized costs not recoverable through a direct sale should be

    charged to expense.

    2.1.1 Accounting for internal costs relating to real estate property acquisitions

    Excerpt from Accounting Standards CodificationReal Estate General Other Assets and Deferred Costs

    Recognition

    970-340-25-5

    The view that all internal costs of identifying and acquiring commercial properties should be deferred

    and, in some manner, capitalized as part of the cost of successful property acquisitions is not

    appropriate.

    970-340-25-6

    Internal costs of preacquisition activities incurred in connection with the acquisition of a property that

    will be classified as nonoperating at the date of acquisition that are directly identifiable with theacquired property and that were incurred subsequent to the time that acquisition of that specific

    property was considered probable (that is, likely to occur) shall be capitalized as part of the cost of

    that acquisition.

    970-340-25-7

    Paragraph970-340-25-17 is also applicable in situations in which the acquired property is partially

    operating and partially nonoperating.

    Subsequent Measurement

    970-340-35-3

    If an entity subsequently determines that a property will be classified as operating at the date of

    acquisition, the internal costs of preacquisition activities shall be charged to expense and any

    additional costs shall be expensed as incurred.

    970-340-35-4

    If an entity subsequently determines that a property will be classified as nonoperating at the date of

    acquisition, previously expensed internal costs of preacquisition activities shall not be capitalized as

    part of the cost of that acquisition.

    http://gaait-aa.ey.net/Document.aspx?PersistentBookId=0&GotoString=d3e29536-110302__d3e29555-110302&ProductId=111#d3e29536-110302__d3e29555-110302http://gaait-aa.ey.net/Document.aspx?PersistentBookId=0&GotoString=d3e29536-110302__d3e29555-110302&ProductId=111#d3e29536-110302__d3e29555-110302
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    Real Estate General Other Expenses

    Recognition

    970-720-25-1

    Internal costs of preacquisition activities incurred in connection with the acquisition of a property that

    will be classified as operating at the date of acquisition shall be expensed as incurred.

    970-720-25-2

    A property would be considered operating if, at the date of acquisition, major construction activity (as

    distinguished from activities such as routine maintenance and cleanup) is substantially completed on

    the property and either of the following conditions exists:

    a. It is held available for occupancy upon completion of tenant improvements by the acquirer.

    b. It is already income-producing.

    Many companies have internal real estate acquisition departments. The employees in these department

    spend their time searching for and managing the acquisition of real estate properties. An entity should

    capitalize internal costs of preacquisition activities if the costs are directly identifiable with a specificnonoperating property, and they were incurred subsequent to the time the acquisition of that specific

    nonoperating property was considered probable. Such costs should only be capitalized if the property w

    be classified as nonoperating at the date of acquisition. If the property will be classified as operating at

    the date of acquisition, internal preacquisition costs should be charged to expense as incurred.

    A property should be considered operating if major construction activity (versus activities such as routin

    maintenance and cleanup) is substantially completed on the property and (a) it is held available for

    occupancy on completion of tenant improvements by the acquirer or (b) it is already income producing.

    For example, an entity planning to purchase an apartment building that is currently occupied by tenants

    should not capitalize the internal costs associated with the acquisition of that property, even if the costs

    are directly identifiable with the property and acquisition of the property is probable. If instead the entit

    was planning to build an apartment building on a specific piece of land and the acquisition of that land isconsidered probable, internal costs directly associated with acquiring the land should be capitalized.

    If an entity initially determines a property will be classified as nonoperating but subsequently determine

    that the property will be classified as operating at the date of acquisition, previously capitalized costs

    should be charged to expense and any additional costs should be charged to expense as incurred.

    However, if an entity initially determines a property will be classified as operating but subsequently

    determines that the property will be classified as nonoperating at the date of acquisition, the entity

    should not capitalize amounts previously charged to expense. The guidance for real estate project costs

    does not address the accounting for the acquisition of a business (see ASC 805 for further details).

    Consistent with ASC 970-340-25-17 (see Section 3.3), if portions of a rental project are substantially

    completed and occupied by tenants or held available for occupancy and other portions have not yetreached that stage, each portion of the project should be accounted for as a separate project. Costs

    should be allocated between the portions under construction (nonoperating) and the portions

    substantially completed and held available for occupancy (operating), and the costs allocated to the

    nonoperating portions should be capitalized if they are directly identifiable with the property and were

    incurred subsequent to the time the acquisition of the property was considered probable, and those

    related to the operating portion should be charged to expense.

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    Illustration 2-3: Potential sites are all nonoperating properties

    Facts:

    Company A is committed to constructing an office building in Boston that will be leased to third parties

    (i.e., the building will not be for internal use). Company A has an internal real estate acquisition

    department that incurs $50,000 in costs while evaluating three potential sites for the building. Onceone of the three sites is selected and is deemed probable of being acquired, the internal real estate

    acquisition department incurs an additional $10,000 in costs directly associated with acquiring the

    selected property.

    Analysis:

    Because the property being acquired is a nonoperating property (Company A is planning to construct

    an office building on the land acquired), Company A should capitalize the $10,000 in costs that were

    incurred after it was probable that the property would be acquired. The $50,000 in costs incurred

    before the acquisition of a specific property was probable (i.e., while evaluating three potential sites)

    should be charged to expense as incurred.

    Illustration 2-4: Potential sites are at various stages of completion

    Facts:

    Company A is committed to owning an office building in Boston that will be leased to third parties

    (i.e., the building will not be for internal use). Company A has an internal real estate acquisition

    department that incurs $50,000 in costs while evaluating three potential properties. Property A is

    under construction; Property B has been recently completed and is available for occupancy; Property

    C is 75-percent occupied. Once one of the three sites is selected and deemed probable of being

    acquired, the internal real estate acquisition department incurs an additional $10,000 in costs directly

    associated with acquiring the selected property.

    Analysis:

    The $50,000 in costs incurred before the acquisition of a specific property was probable should be

    charged to expense as incurred. Additionally, Company A should only capitalize the additional

    $10,000 in costs directly associated with acquiring the selected property if the property that is under

    construction (Property A) is selected. The other two properties (Properties B and C) would be

    considered operating properties and, as such, no preaquisition costs should be capitalized.

    2.2 Taxes and insurance

    Excerpt from Accounting Standards CodificationReal Estate General Other Assets and Deferred Costs

    Recognition

    970-340-25-8

    Costs incurred on real estate for property taxes and insurance shall be capitalized as property cost

    only during periods in which activities necessary to get the property ready for its intended use are in

    progress. The phrase activities necessary to get the property ready for its intended use are in progress

    is used here with the same meaning as it has for interest capitalization in paragraphs 835-20-25-3

    through 25-4 and 835-20-25-8. Costs incurred for such items after the property is substantially

    complete and ready for its intended use shall be charged to expense as incurred. The phrase

    substantially complete and ready for its intended useis used here with the same meaning as it has for

    interest capitalization in paragraph 835-20-25-5.

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    Costs incurred for property taxes and insurance on real estate should be accounted for in a manner that

    is similar to interest costs, which are addressed in ASC 835-20, Interest Capitalization of Interest(see

    Section 2.2.3), in that the period of capitalization is the same. Property taxes and insurance costs shou

    only be capitalized during periods in which activities necessary to get a property ready for its intended

    use are in progress. ASC 835-20-20 indicates that the term activitiesis to be construed broadly

    and encompasses more than just physical construction. For example, preconstruction activities, such

    as developing plans or obtaining permits, and activities undertaken to overcome unforeseen obstacles,

    such as technical problems, labor disputes, or litigation, would all qualify as activities necessary to get

    the property ready for its intended use. If an entity suspends substantially all activities related to the

    project, tax and insurance cost capitalization should cease until activities are resumed. However, an

    entity is not required to suspend cost capitalization for brief interruptions, interruptions that are

    externally imposed, or delays that are inherent in the development process. Taxes and insurance

    should not be capitalized if the owner is simply holding the property for future development, but has

    not commenced development activities.

    Once the property is substantially complete and ready for its intended use, tax and insurance costs

    should be charged to expense as incurred. The point at which an asset is substantially complete and

    ready for its intended use depends on the nature of the asset (ASC 835-20-25-5). Some assets are

    completed in stages and the completed stages can be used while work is continuing on the other stages

    (e.g., individual condominium units or individual floors in an office building). Other assets must be

    completed in their entirety before any part of the asset can be used (e.g., a warehouse that will be lease

    to one tenant). If some portions of an asset are substantially complete and ready for use and other

    portions have not yet reached that stage, the substantially completed portions should be accounted for

    as a separate project and capitalization of tax and insurance costs on that portion of the project should

    cease. A project held for occupancy (rental property) is substantially complete and held available for

    occupancy upon the completion of tenant improvements by the developer but no later than one year

    from cessation of major construction activity (as distinguished from activities such as routine

    maintenance and cleanup). See Section 3.3 for additional details.

    2.2.1 Accounting for special assessments and tax increment financing entitiesExcerpt from Accounting Standards CodificationReal Estate General Debt

    Overview and Background

    970-470-05-2

    Municipalities often levy special assessments to finance the construction of certain infrastructure

    assets or improvements or may levy special assessments for other specified purposes. Alternatively,

    an entity that intends to develop real estate it owns or leases may form a tax increment financing

    entity to finance and operate the project infrastructure. Tax increment financing entities are

    authorized under various state statutes to issue bonds to finance the construction of road, water, and

    other utility infrastructure for a specific project. Usually, all of the debt is issued by the tax increment

    financing entity and will be repaid by future user fees or taxes assessed to cover operating costs, such

    as repairs and maintenance, as well as debt service.

    970-470-05-3

    The Variable Interest Entities Subsections of Subtopic 810-10address consolidation by business

    entities of variable interest entities (VIEs), which may include many special-purpose entities of the type

    used as tax increment financing entities.

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    Recognition

    970-470-25-1

    If the special assessment or the assessment to be levied by the tax increment financing entity on each

    individual property owner is a fixed or determinable amount for a fixed or determinable period, there i

    a presumption that an obligation shall be recognized by the property owner. Further, with respect to

    tax increment financing entities, factors such as the following indicate that an entity may becontingently liable for tax increment financing entity debt, and recognition of an obligation shall be

    evaluated under Topic 450:

    a. The entity must satisfy any shortfall in annual debt service obligations.

    b. There is a pledge of entity assets.

    c. The entity provides a letter of credit in support of some or all of the tax increment financing entitydebt or provides other credit enhancements.

    970-470-25-2

    If the entity is constructing facilities for its own use or operation, the presence of any of the factors in

    the preceding paragraph creates a presumption that the tax increment financing entity debt must be

    recognized as an obligation of the entity.

    970-470-25-3

    An entitys agreement to either make up shortfalls in the annual debt service requirements or

    guarantee the tax increment financing entitys debt, as described in Example 1, Cases C through D (se

    paragraphs 970-470-55-9 through 55-14), may be guarantees under the characteristics found in

    paragraph 460-10-15-4 and subject to the initial recognition, initial measurement, and disclosure

    requirements of Topic460.

    970-470-25-4

    See Section970-470-55 for examples of accounting for special assessments and tax increment

    financing entities.

    970-470-25-5

    See Section974-605-25 for adjustment of assets (or liabilities) transferred between a real estate

    investment trust and its adviser.

    Infrastructure assets or improvements, such as roads, water lines, and other utilities, are often financed

    through special tax assessments. A municipality may levy a special assessment to finance the

    infrastructure or a real estate developer may form a Tax Increment Financing Entity (TIFE) that is

    authorized to issue bonds to finance and operate the project infrastructure. When a TIFE issues bonds,

    the debt is generally repaid by future user fees or taxes assessed on the property to cover operating

    costs, such as repairs and maintenance, and debt service (i.e., the property owner is responsible forrepaying the debt and the repayment obligation remains attached to the property if it is sold).

    ASC 970-470, Real Estate General Debt, addresses whether companies should recognize a liability

    for special assessments from municipalities or for TIFE debt. Under this guidance, there is a presumptio

    that an obligation should be recognized if the assessment to be levied by the municipality or TIFE on eac

    individual property owner is fixed or determinable (i.e., a fixed or determinable amount for a fixed or

    determinable period).

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    Even if the assessment to be levied by a TIFE on each individual property owner is not fixed or

    determinable, factors such as the following are indicators that an entity may be contingently liable for TIFE

    debt, and recognition of an obligation should be evaluated using the guidance in ASC 450, Contingencies:

    The entity must satisfy any shortfall in annual debt service obligations

    There is a pledge of company assets

    The entity provides a letter of credit in support of some or all of the TIFE debt or provides other

    credit enhancements

    If an entity is constructing facilities for its own use or operation (this would include rental or sale), the

    presence of any of the above factors creates a presumption that the TIFE debt should be recognized as

    an obligation of the entity.

    The following examples are included in the accounting guidance for special assessments and tax incremen

    financing entities (ASC 970-470) and demonstrate the application of this guidance to specific situations:

    Excerpt from Accounting Standards Codification

    Real Estate

    General

    DebtImplementation Guidance and Illustrations

    970-470-55-2

    Cases A, B, C, and D share the following assumptions:

    a. The entity owns 100 percent of the land under development.

    b. $10 million of bonds are issued for construction of the development infrastructure.

    c. The interest rate on the bonds is 6 percent and the term is 20 years.

    d. The annual debt service requirement is $500,000 principal repayment plus interest accrued

    during the year.

    e. The project is expected to take 10 years to complete, and no significant sales of property areexpected until the third year. All of the property under development is intended for sale.

    f. The property under development is subject to lien if there is a default on the assessment.

    Case A: Municipality Bond Issue; Entity Obligation Recognized for Special Assessment

    970-470-55-3

    A municipality issues bonds to finance construction of the infrastructure assets. The municipality

    levies a special assessment on the property that is equal to the face amount of the bonds. The special

    assessment bears interest at the same rate as the bonds. In this Case, if there are 100 equal-sized

    parcels in the development, each parcel will be assessed $5,000 per year plus accrued interest for20 years. The assessment remains with the property. Accordingly, upon sale or partial sale of the

    development, the entity must pay the remaining assessment on the property sold or the purchaser

    must assume the obligation.

    970-470-55-4

    The entity must recognize an obligation for the special assessment because the amount is fixed for a

    fixed period of time. Subsequent property owners that assume the obligation must recognize the

    obligation related to the parcels purchased.

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    Case B: Tax Increment Financing Entity; Entity Obligation Recognized for Debt

    970-470-55-5

    A tax increment financing entity is formed to issue bonds. On completion of construction of the

    infrastructure assets, title to such assets (including any land upon which the infrastructure is

    constructed) passes from the tax increment financing entity to the municipality. The entity does not

    guarantee the tax increment financing entity debt.

    970-470-55-6

    Property owners will be subject to a tax on an equal basis determined by the number of lots in the

    district. The tax will be levied annually, based on the tax increment financing entity s debt service

    requirement for that year. Accordingly, if there are 100 parcels in the development, $5,000 plus

    interest accrued for the year is expected to be levied on each parcel annually for the 20 years the

    debt is outstanding. Additional assessments may be levied by the tax increment financing entity

    for maintenance or other services. These assessments are in addition to normal property

    tax assessments.

    970-470-55-7

    Upon sale of a portion of the property, either the entity must repay a pro rata portion of the tax

    increment financing entity debt or the purchaser must assume the obligation.

    970-470-55-8

    The entity must recognize an obligation for the tax increment financing entity debt because the

    assessment in this example is a determinable amount for a determinable period of time.

    Case C: Tax Increment Financing Entity; No Entity Obligation Recognized

    970-470-55-9

    A tax increment financing entity is formed to issue bonds. On completion of construction of the

    infrastructure assets, title to such assets (including any land upon which the infrastructure is

    constructed) passes from the tax increment financing entity to the municipality. The entity does not

    guarantee the tax increment financing entity debt.

    970-470-55-10

    The rates for annual assessments are determined prior to issuance of the debt and are limited to a

    maximum annual tax rate based on anticipated debt service requirements. The rate levied is

    dependent on the land use category of each parcel of property in the district. Developed property is

    taxed at the maximum rate, unless a lesser amount is needed to meet current year debt service and

    maintenance obligations. If the amount levied for developed property is not sufficient, undeveloped

    property is subject to tax up to the maximum rate. If the maximum rate applied to both developed and

    undeveloped property is insufficient, additional taxes may be assessed only if approved by eligible

    voters.

    970-470-55-11

    Because the assessment on each individual property owner is dependent upon the rate of developmen

    and, therefore, is not fixed or determinable, an obligation is not required to be recognized. However, if

    the entity must satisfy any shortfall in annual debt service requirements, recognition of an obligation

    must be evaluated pursuant to Subtopic 450-20.

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    Case D: Tax Increment Financing Entity; No Entity Obligation Recognized

    970-470-55-12

    A tax increment financing entity is formed to issue bonds. On completion of construction of the

    infrastructure assets, title to such assets (including any land upon which the infrastructure is

    constructed) passes from the tax increment financing entity to the municipality. The entity does not

    guarantee the tax increment financing entity debt.

    970-470-55-13

    The debt service requirements of the tax increment financing entity will be met by normal property tax

    assessments. The increased value of the developed property is expected to generate sufficient taxes

    to meet the debt service and other obligations. If such assessments are not sufficient, the municipality

    must satisfy the shortfall.

    970-470-55-14

    The assessment on each individual property is not determinable because it is based on the current tax

    rate and the assessed value of the property. Accordingly, the entity is not required to recognize an

    obligation. The assessments will be treated as property taxes. If, however, the company had

    guaranteed the tax increment financing entity debt or must satisfy any shortfall in annual debt servicerequirements, the recognition of an obligation would be evaluated pursuant to Subtopic 450-20.

    The potential effects of guarantees (such as an entity s agreement to make up shortfalls in the annual

    debt service requirements or guarantee the tax increment financing entitys debt) and consolidation

    considerations for special-purpose entities of the type used as tax increment financing entities should

    also be considered. See the guidance for guarantees and special-purpose entities in ASC 460,

    Guarantees, and the Variable Interest Subsections of ASC 810, Consolidations, for more details.

    ASC 970-470 only addresses when a liability should be recorded for a special assessment or TIFE debt

    and not whether an asset or expense should be recognized when the liability is recorded. Generally, onc

    construction of the infrastructure assets is complete, title to the assets (including any land on which the

    infrastructure is constructed) passes from the TIFE to the municipality. Although the developer does no

    retain title to the assets, we believe the costs associated with a special assessment or TIFE debt relate t

    the overall development of the real estate project and should be capitalized as project costs. This

    treatment is consistent with the treatment of real estate donated to municipalities for use that will

    benefit the project which is allocated as a common cost of the project (ASC 970-360-35-1, see Section

    2.9 for further discussion).

    When an entity has recorded a liability in accordance with ASC 970-470 and the property to which the

    obligation is attached is sold, the extinguished liability and capitalized costs should be included in the pro

    or loss calculation. If a transaction does not qualify for sales treatment, the obligation and capitalized

    costs should remain on the sellers balance sheet (refer to our Financial Reporting Developments booklet

    Real Estate Salesfor additional guidance on accounting for the sale of real estate).

    2.2.2 Rental costs incurred during a construction period

    In some lease arrangements, a lessee may have the right to use leased property prior to commencing

    operations or making rental payments in order to construct a lessee asset (e.g., leasehold

    improvements). The accounting guidance for leases (ASC 840-20-25-10 through 25-11) prohibits an en

    user lessee from capitalizing rent under an operating lease into the cost of a constructed asset (refer to

    our Financial Reporting Developments booklet, Lease Accounting A Summary, for additional

    information). However, the accounting guidance for leases does not address whether a lessee that

    accounts for the sale or rental of real estate projects under the applicable guidance in ASC 970 should

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    capitalize rental costs associated with ground and building operating leases. Therefore, we believe that

    whether a lessee accounting for the sale or rental of real estate projects in accordance with ASC 970

    capitalizes or expenses rental costs associated with ground and building operating leases is a policy

    election that should be disclosed and consistently applied. If capitalized, the period of capitalization and

    related accounting should follow ASC 970-340-25-8 (see Section 2.2 for further details).

    2.2.3 Interest

    ASC 835-20, Interest Capitalization of Interest, establishes standards of financial accounting and

    reporting for capitalizing interest cost as a part of the historical cost of acquiring certain assets. Assets

    that qualify for capitalization of interest include: assets that are constructed or otherwise produced for

    an enterprises own use; assets intended for sale or lease that are constructed or otherwise produced as

    discrete projects (e.g., real estate projects subject to the applicable guidance in ASC 970); and

    investments (e.g., equity, loans, and advances) accounted for by the equity method if the investee has

    activities in progress necessary to commence its planned principal operations provided that the

    investees activities include the use of funds to acquire qualifying assets (refer to ASC 835-20).

    As discussed in Section 2.2, interest costs and costs incurred for property taxes and insurance on real

    estate should be accounted for in a similar manner. Interest should only be capitalized during periods inwhich activities necessary to get the property ready for its intended use are in progress (or in the case o

    an equity method investment, until the planned principal operations of the investee begin). If an entity

    suspends substantially all activities related to the project, cost capitalization should cease until activities

    are resumed. However, an entity is not required to suspend cost capitalization for brief interruptions,

    interruptions that are externally imposed, or delays that are inherent in the development process.

    2.3 Project costs

    Excerpt from Accounting Standards CodificationProject Costs

    Costs clearly associated with the acquisition, development, and construction of a real estate project.

    Indirect Project Costs

    Costs incurred after the acquisition of the property, such as construction administration (for example,

    the costs associated with a field office at a project site and the administrative personnel that staff the

    office), legal fees, and various office costs, that clearly relate to projects under development or

    construction. Examples of office costs that may be considered indirect project costs are cost

    accounting, design, and other departments providing services that are clearly related to real estate

    projects.

    Real Estate General Property, Plant, and Equipment

    Recognition

    970-360-25-2

    Project costs clearly associated with the acquisition, development, and construction of a real estate

    project shall be capitalized as a cost of that project.

    970-360-25-3

    Indirect project costs that relate to several projects shall be capitalized and allocated to the projects to

    which the costs relate.

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    Real Estate General Other Expenses

    Recognition

    970-720-25-3

    Indirect costs that do not clearly relate to projects under development or construction, including

    general and administrative expenses, shall be charged to expense as incurred.

    Costs that are clearly associated with the acquisition, development, and construction of a real estate

    project should be capitalized as project costs. Direct project costs include costs such as the cost of land

    acquisition, building materials, or project plans. Indirect project costs should be capitalized if they clearl

    relate to the specific real estate project or several different projects (all of which qualify for

    capitalization) under development. Indirect project costs that are clearly related to the real estate proje

    or projects may include construction administration costs (e.g., costs associated with a field office at a

    project site), legal fees, and various other costs (e.g., cost accounting and design). If indirect project

    costs are associated with several projects under development, the costs should be allocated to the

    projects on a consistent and rational basis. Indirect costs that do not clearly relate to the acquisition,

    development, or construction of a real estate project, including most general and administrative costs,

    should be charged to expense as incurred.

    It may often be difficult to distinguish between indirect project costs that should be capitalized and

    general and administrative costs that should be charged to expense. This is further complicated by the

    fact that one entity may include appropriately capitalizable costs in a separate development departmen

    while another entity may not. In general, we believe there is a presumption that shared costs should not

    be capitalized unless they are incremental to development (i.e., the costs would not have been incurred

    in the absence of the project or projects under development).

    2.3.1 Accounting for asset retirement obligations, the costs of asbestos removal,

    and costs to treat environmental contamination

    An entity may incur costs to remove, contain, neutralize, or prevent existing or future environmental

    contamination of a property. These costs may be incurred voluntarily or may be required by law.Additionally, various federal, state, and local laws require the removal or containment of dangerous

    asbestosin buildings and regulate the manner in which the asbestos should be removed or contained.

    ASC 410-20,Asset Retirement and Environmental Obligations Asset Retirement Obligations, applies t

    legal obligations associated with the retirement of a tangible long-lived asset that result from the

    acquisition, construction, development, and (or) the normal operation of a long-lived asset. In ASC 410-

    20, a legal obligation is an obligation a party is required to settle as a result of an existing or enacted law

    statute, ordinance, written or oral contract, or a promise and an expectation of performance (i.e., unde

    the doctrine of promissory estoppel.)

    For asset retirement obligations accounted for in accordance with ASC 410-20, the fair value of the liabilit

    for asset retirement obligations is recognized in the period in which it is incurred, or in the period in which

    a property with an existing retirement obligation is acquired, provided that a reasonable estimate of fairvalue can be made. Upon initial recognition, the costs are capitalized as part of the carrying amount of

    the related long-lived asset. For example, an asset retirement obligation may result from construction

    (e.g., construction of an asset creates the obligation to dismantle and remove the asset at some point in th

    future), in which case the obligation would be recognized as the asset is constructed. In another example,

    the asset retirement obligation could result from a new law (e.g., a new law that requires the replacement

    of all the pipes in an office building at some point in the future), in which case the obligation would be

    recognized at the time that the new law is enacted. Refer to our Financial Reporting Developments bookle

    Asset Retirement Obligations, for detailed guidance on the accounting for asset retirement obligations.

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    An environmental remediation liability that results from the normal operation of a long-lived asset and

    that is associated with the retirement of that asset is within the scope of ASC 410-20. However, an

    environmental remediation liability that results from other than the normal operation of a long-lived

    asset should fall within the scope of ASC 410-30,Asset Retirement and Environmental Obligations

    Environmental Obligations. For example, environmental remediation liabilities that relate to pollution

    arising from some past act (e.g., a Superfund violation) that will be corrected without regard to

    retirement activities are subject to the provisions of ASC 410-30.Similarly, for the costs of asbestos

    removal that result from the other-than-normal operation of an asset are not within the scope of ASC

    410-20 but may be subject to the provisions of ASC 410-30 (e.g., if the company has an obligation to

    remove the asbestos). Refer to our Financial Reporting Developments booklet, Environmental

    Obligations,for more details.

    The guidance for environmental obligations may also apply to costs incurred to remove asbestos or trea

    environmental contamination that do not relate to a legal obligation, such as costs to voluntarily improv

    the safety of an asset (e.g., voluntarily removing asbestos in a foreign jurisdiction where no laws exist to

    obligate its removal or voluntarily removing the lead pipes in a building and replacing them with copper

    pipes to improve the safety of the buildings water system) or costs to prepare the property for sale.

    However, as demonstrated by two of the illustrative examples in ASC 410-20-55, asbestos removal will

    generally fall within the guidance for asset retirement obligations. In the unusual event that asbestosremoval costs are not accounted for using the guidance for asset retirement obligations (ASC 410-20), the

    guidance for environmental obligations (ASC 410-30) would apply and the costs of asbestos removal may b

    capitalized and/or deferred in the following situations:

    If costs are incurred within a reasonable time period after a property with a known asbestos problem

    is acquired, the costs should be capitalized as part of the cost of the acquired property, subject to a

    impairment test (i.e., the guidance for the impairment of long-lived assets in ASC 360-10) for that

    property.

    If costs are incurred to treat asbestos in an existing property, the costs may be capitalized as a

    betterment, subject to an impairment test for that property.

    If costs are incurred in anticipation of a sale of property, they should be deferred and recognized in

    the period of sale to the extent those costs are recoverable based on the estimated sales price.

    In general, other costs incurred to treat environmental contamination (not within the scope of ASC 410-20

    should be charged to expense as incurred in accordance with the guidance for environmental obligation

    (ASC 410-30). Those costs may be capitalized if recoverable but only if any one of the following criteria

    is met:

    The costs extend the life, increase the capacity, or improve the safety or efficiency of property

    owned by the entity. The condition of the property after the costs are incurred must have improved

    as compared with the condition of the property when originally constructed or acquired, if later. For

    example, costs incurred to remove lead pipes in an office building and replace them with copper

    pipes to improve the safety of the buildings water system compared with its condition when thewater system was originally acquired may be capitalized if the costs are recoverable.

    The costs mitigate or prevent environmental contamination that has yet to occur and that otherwise

    may result from future operations or activities. Additionally, the costs improve the property compare

    with its condition when constructed or acquired, if later. For example, the costs of installing water

    filters in a well to prevent future contamination may be capitalized if the costs are recoverable.

    The costs are incurred in preparing property for sale that is currently held for sale.

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    2.3.2 Accounting for demolition costs

    An entity may purchase property with the intention of demolishing the existing structure and replacing

    with a new structure or with the intention of reconstructing the interior of the building (e.g., gutting the

    interior of a warehouse in preparation for reconstructing the interior as office space). Alternatively, an

    entity may purchase property with the intention of operating the property, but later decide to demolish

    and replace the property with a new structure. When there is a change in the use of real estate(e.g., when a golf course is converted to an office building complex), the guidance for real estate project

    costs (ASC 970-360-35-2) indicates that the previously capitalized development and construction costs

    need not be written off if certain conditions are met (see Section 2.10). However, the guidance for real

    estate project costs does not address demolition costs or the accounting for previously capitalized

    development and construction costs when there is no change in use (i.e., a 20-year old hotel is

    demolished and replaced with a new hotel).

    Demolition costs incurred in conjunction with the acquisition of real estate may be capitalized as part of

    the cost of the acquisition if the demolition (a) is contemplated as part of the acquisition and (b) occurs

    within a reasonable period of time after the acquisition, or is delayed, but the delay is beyond the entity

    control (e.g., demolition cannot commence until the end of an existing tenant s lease term, which will

    expire shortly after acquisition or demolition is subject to governmental permitting processes). If anentity purchases property with the intention of demolishing the existing structure and replacing it with a

    new structure, the entire purchase price and the costs of demolition should be allocated to the cost of

    the land.

    Illustration 2-5: Demolition costs

    Facts:

    Company A acquires land with a preexisting structure from Company B. Due to the nature and age of

    the structure on the site, the land is worth more without the structure than with the structure. Soon

    after the acquisition, Company A, as contemplated at the time of purchase, incurs costs to demolish

    the structure.

    Analysis:

    It is appropriate for Company A to capitalize the costs to demolish the structure as incremental costs

    of the acquired land.

    If an entity purchases a property with the intention of demolishing and rebuilding the interior of the

    building only, the purchase price and costs of demolition should be allocated between the land and

    building with the demolition component assigned solely to the building.

    If a demolition was not contemplated as part of an acquisition of real estate or the demolition does not

    occur within a reasonable period of time after the acquisition, the costs of the demolition should be

    charged to expense as incurred, unless the demolition is accounted for as an asset retirement obligation(ARO) in accordance with ASC 410-20.

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    2.4 Amenities

    Excerpt from Accounting Standards CodificationAmenities

    Features that enhance the attractiveness or perceived value of a time-sharing interval. Examples of

    amenities include golf courses, utility plants, clubhouses, swimming pools, tennis courts, indoor

    recreational facilities, and parking facilities. See also Planned Amenities and Promised Amenities.

    Common Costs

    Costs that relate to two or more units or phases within a real estate or time-sharing project.

    Real Estate General Other Assets and Deferred Costs

    Recognition

    970-340-25-9

    Accounting for costs of amenities shall be based on managements plans for the amenities in

    accordance with the following:

    a. If an amenity is to be sold or transferred in connection with the sale of individual units, costs inexcess of anticipated proceeds shall be allocated as common costsbecause the amenity is clearly

    associated with the development and sale of the project. The common costs include expected

    future operating costs to be borne by the developer until they are assumed by buyers of units in a

    project.

    b. If an amenity is to be sold separately or retained by the developer, capitalizable costs of theamenity in excess of its estimated fair value as of the expected date of its substantial physical

    completion shall be allocated as common costs. For the purpose of determining the amount to be

    capitalized as common costs, the amount of cost previously allocated to the amenity shall not be

    revised after the amenity is substantially completed and available for use. A later sale of the

    amenity at more or less than its estimated fair value as of the date of substantial physical

    completion, less any accumulated depreciation, results in a gain or loss that shall be included in

    net income in the period in which the sale occurs.

    970-340-25-10

    Costs of amenities shall be allocated among land parcels benefited and for which development is

    probable. A land parcel may be considered to be an individual lot or unit, an amenity, or a phase. The

    fair value of a parcel is affected by its physical characteristics, its highest and best use, and the time

    and cost required for the buyer to make such use of the property considering access, development

    plans, zoning restrictions, and market absorption factors.

    970-340-25-11

    Before an amenity is substantially completed and available for use, operating income (or loss) of the

    amenity shall be included as a reduction of (or an addition to) common costs. When an amenity to be

    sold separately or retained by the developer is substantially completed and available for use, current

    operating income and expenses of the amenity shall be included in current operating results.

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    Real estate projects commonly include amenities, such as golf courses, utility plants, clubhouses,

    swimming pools, tennis courts, indoor recreational facilities, and parking facilities. Companies should

    account for the costs of amenities based on management s plans for the amenities as follows:

    If management plans to sell or transfer an amenity in connection with the sale of individual units

    (e.g., a clubhouse that will be transferred to the homeowners association in a housing development)

    the amenity is clearly associated with the development, and sale of the project and costs in excess oanticipated proceeds should be accounted for as common costs (costs that relate to two or more

    units within a real estate project), and allocated to the individual units based on the relative fair valu

    of each unit before construction (see Section 2.6 for additional guidance on allocating common

    costs). The transfer of an amenity is equivalent to a sale for no consideration (i.e., 100 percent of

    costs are common costs). Allocated costs should include expected future operating costs to be born

    by the developer until the asset is sold or transferred. Any operating income realized by the

    developer from the amenity prior to the amenity being sold or transferred should be recorded as a

    reduction in common costs.

    If management does not plan to sell or transfer an amenity in connection with the sale of individual

    units (i.e., management plans to sell the amenity separately or retain the amenity), only capitalizabl

    costs in excess of the estimated fair value of the amenity as of the expected date of its substantialphysical completion should be accounted for as common costs and allocated to the individual units

    based on the relative fair value of each unit before construction (see Section 2.6 for additional

    guidance on allocating common costs). The costs not allocated to individual units should be

    capitalized as a separate asset and depreciation of the asset should commence when the amenity is

    substantially complete and available for use. The costs allocated to the amenity should not be revise

    after the amenity is substantially completed and available for use. A later sale of the amenity at mo

    or less than its estimated fair value, less any accumulated depreciation, will result in a gain or loss

    that should be included in net income in the period in which the sale occurs unless previously

    impaired. Operating income (or loss) of the amenity before it is substantially complete and ready fo

    its intended use should be included as a reduction of (or an addition to) common costs. After the

    amenity is substantially complete and ready for its intended use, operating income (or loss) should

    included in current operating results.

    Illustration 2-6: Amenity to be transferred in connection with sale of individual units

    Facts:

    Developer As plans for a 100-unit single family home project include the construction of a recreationa

    facility that will be transferred to the homeowners association once 50 percent of the homes are sold.

    Costs of constructing the facility are estimated to be $75,000 and Developer A anticipates incurring

    $10,000 in operating losses between the time the facility is substantially completed and available for

    use, and when it is transferred to the homeowners association.

    Analysis:

    Because Developer A plans to transfer the recreational facility in connection with the sale of individual

    units (i.e., to the homeowners), the $75,000 in costs incurred to construct the facility should be

    accounted for as common costs (i.e., proceeds will be zero) and allocated to the individual homes

    based on the relative fair value of each lot before construction (see Section 2.6 for additional guidance

    on allocating common costs). Additionally, the $10,000 in operating losses incurred by Developer A

    prior to transferring the property to the homeowners should be allocated to the individual homes as

    common costs.

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    Illustration 2-7: Amenity to be sold in connection with sale of individual units

    Facts:

    Assume the same facts as in Example 1, except that Developer A plans to sell the recreational facility

    to the homeowners association for $30,000.

    Analysis:

    Because Developer A plans to sell the recreational facility in connection with the sale of individual

    units, the $55,000 in costs that are in excess of anticipated proceeds from the sale ($75,000 costs +

    $10,000 in operating losses prior to sale $30,000 sales price) should be accounted for as common

    costs and allocated to the individual homes based on the relative fair value of each lot before

    construction (see Section 2.6 for additional guidance on allocating common costs).

    Illustration 2-8: Amenity to be sold to a third party

    Facts:

    Assume the same facts as in Example 1, except that Developer A plans to sell the recreational facility

    to a third party that will operate the facility for a profit. The estimated fair value of the facility as of the

    expected date of its substantial physical completion is $80,000.

    Analysis:

    Because Developer A plans to sell the recreational facility separately from the sale of individual units

    and the estimated fair value of the property as of the expected date of its substantial physical

    completion is more than the estimated construction costs (estimated fair value $80,000 versus

    $75,000 in estimated construction costs), none of the construction costs should be allocated to the

    individual units. The $75,000 in construction costs should be recorded as a fixed asset and

    depreciation should commence once the facility is substantially complete and available for use. Whenthe facility is sold, Developer A should record the difference between the sales price and the book

    value of the asset, if any, as a gain or loss in the period of sale and not as a common cost to be

    allocated to the individual homes. Additionally, the $10,000 in operating losses incurred by Developer

    A after the property is substantially complete and available for use should not be allocated to the

    individual homes as common costs, but should be included in current operating results. See ASC 970-

    340-25-11 for a discussion of operating income or loss of amenities generated prior to the amenities

    being substantially completed and available for use.

    2.5 Incidental operations

    Excerpt from Accounting Standards CodificationIncidental Operations

    Revenue-producing activities engaged in during the holding or development period to reduce the cost

    of developing the property for its intended use, as distinguished from activities designed to generate a

    profit or a return from the use of the property.

    Incremental Revenues from Incidental Operations

    Revenues that would not be produced except in relation to the conduct of incidental operations.

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    Incremental Costs of Incidental Operations

    Costs that would not be incurred except in relation to the conduct of incidental operations. Interest,

    taxes, insurance, security, and similar costs that would be incurred during the development of a real

    estate project regardless of whether incidental operations were conducted are not incremental costs.

    Real Estate General Other Assets and Deferred Costs

    Recognition

    970-340-25-12

    Incremental revenue from incidental operations in excess of incremental costs of incidental operation

    shall be accounted for as a reduction of capitalized project costs. Incremental costs in excess of

    incremental revenue shall be charged to expense as incurred, because the incidental operations did

    not achieve the objective of reducing the costs of developing the property for its intended use.

    Incidental operations are defined as revenue-producing activities engaged in during the holding or

    development period to reduce the cost of developing the property for its intended use, as distinguished

    from activities designed to generate a profit or a return from the use of the property. Incidental

    operations do not include revenue generated from amenities because amenities are improvements thatare developed to increase the value of the project and not reduce the cost of developing the project. The

    accounting for amenities is described in Section 2.4. Incremental revenue from incidental operations in

    excess of incremental costs should be accounted for as a reduction of capitalized project costs. If

    incremental costs exceed incremental revenue, the difference should be charged to expense, and not

    treated as an increase in capitalized project costs, because the incidental operations did not achieve the

    objective of reducing the costs of developing the property.

    Incremental costs of incidental operations are costs that would not be incurred except in relation to the

    conduct of incidental operations. Therefore, incremental costs do not include interest, taxes, insurance,

    security, and other costs that would be incurred during development regardless of whether incidental

    operations are conducted.

    Illustration 2-9: Incidental operations

    Facts:

    Developer A is constructing an office building on undeveloped land. To offset the cost of development

    Developer A decides to sell the lumber that is cleared from the land for $50,000. Developer A incurs

    $20,000 in costs to clear the land and $10,000 to identify a buyer and ship the lumber.

    Analysis:

    Developer A should account for the proceeds from the sale of the lumber in excess of incremental

    costs as a reduction of capitalized project costs. Because the costs incurred to clear the land would be

    incurred regardless of whether the lumber was sold or discarded, the $20,000 in costs to clear theland would not be considered incremental costs. Therefore, the $50,000 proceeds from the sale less

    the $10,000 in incremental costs incurred to identify a buyer and ship the lumber, or $40,000, should

    be recorded as a reduction of capitalized project costs. This example presumes the costs to dispose of

    the timber, were the land simply cleared, which are not incremental costs, are not significant. Because

    clearing the land to build an office building is clearly associated with the development of a real estate

    project, the $20,000 in costs incurred to clear the land should be capitalized as a project cost.

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    2.6 Allocation of capitalized costs to the components of a real estate project

    Excerpt from Accounting Standards CodificationRelative Fair Value Before Construction

    The fair value of each land parcel in a real estate project in relation to the fair value of the other

    parcels in the project, exclusive of value added by on-site development and construction activities.

    Real Estate General Property, Plant, and Equipment

    Initial Measurement

    970-360-30-1

    The capitalized costs of real estate projects shall be assigned to individual components of the project

    based on specific identification. If specific identification is not practicable, capitalized costs shall be

    allocated as follows:

    a. Land cost and all other common costs, including the costs of amenities to be allocated as common

    costs per paragraphs 970-340-25-9 through 25-11(before construction), shall be allocated to

    each land parcel benefited. Allocation shall be based on the relative fair value before construction

    b. Construction costs shall be allocated to individual units in the phase on the basis of relative sales

    value of each unit.

    If allocation based on relative value also is impracticable, capitalized costs shall be allocated based on

    area methods (for example, square footage) or other value methods as appropriate under the

    circumstances.

    Because components of a real estate project are often sold separately (e.g., the sale of individual home

    in a housing development), costs capitalized for preacquisition costs, property taxes, insurance and

    amenities must be allocated to the individual components of a real estate project. If capitalized costs of

    project are specifically related to an individual component of the project (e.g., the cost of constructing a

    individual home), the costs should be assigned to that component. If specific identification is not

    practicable, capitalized costs should be allocated as follows:

    Land cost and all other common costs incurred prior to construction should be allocated to each lan

    parcel benefited based on the relative fair value of the parcel before construction. Common costs

    may include the cost of amenities (see Section 2.4) and infrastructure, such as sewer and water

    lines, drainage systems, roads, and sidewalks. If it is possible to specifically identify these costs with

    a smaller component of the project rather than the entire project (e.g., one street within a housing

    development versus the main entry to a master planned community), costs should first be allocated

    to the smaller component, and then allocated to individual units based on the relative fair value

    before construction.

    A land parcel may be considered to be an individual lot or unit, an amenity, or aphase.The fair valu

    of a parcel is affected by its physical characteristics, its highest and best use, and the time and cost

    required for the buyer to make such use of the property considering access, development plans,zoning restrictions, and market absorption factors (ASC 970-340-25-10 see Section 2.4).

    Construction costs should be allocated to individual units in a phase based on the relative sales valu

    of each unit. Because all units may not be ready for sale at the same time, it may be necessary to

    estimate the sales value of the unfinished units to properly allocate capitalized costs to all units.

    If allocation based on specific identification and relative value is impracticable, capitalized costs sha

    be allocated based on area methods, such as acreage or square footage, or other value methods as

    appropriate under the circumstances.

    http://asc.fasb.org/glossarysection&trid=2156237&id=SL2281308-110302http://asc.fasb.org/glossarysection&trid=2156237&id=SL2281308-110302http://asc.fasb.org/glossarysection&trid=2156237&id=SL2281308-110302http://asc.fasb.org/glossarysection&trid=2156237&id=SL2281308-110302
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    The guidance for real estate project costs indicates that land and all other common costs incurred prior

    to construction, including the cost of amenities, should be allocated to each land parcelbenefited based

    on the relative fair value before construction. However, it is unclear how this guidance should be applied

    to the construction of condominium units or other structures that include more than one unit on the

    same land parcel. It is often impracticable to allocate costs to these units based on their relative fair

    value before construction, because the units do not exist before construction. Therefore, because the

    guidance for real estate project costs indicates that area methods or other value methods should be use

    if allocation based on relative value is impracticable, we believe it would generally be appropriate to

    allocate land and common costs to these types of structures based on the relative sales value of each

    unit after construction. Whenever possible, costs should be allocated so that there is a consistent profit

    margin on the sale of individual units.

    Illustration 2-10: Allocation of costs to project components

    Facts:

    Company A purchases land zoned for residential use for $320,000. Company As plans for the land

    include 50 single-family homes and a swimming pool that will be transferred to the homeowners

    association once 50 percent of the homes are sold. Company A estimates that it will incur $10,000 incosts to build the swimming pool and $90,000 in other common costs not directly associated with

    individual homes for sewer lines, roads, and sidewalks. Company A determined the fair value

    (considering the criteria in ASC 820, Fair Value Measurements and Disclosures) of30 of the 50 half

    acre lots is $10,000 per lot ($300,000 in total) and the fair value of 20 of the 50 half acre lots is

    $20,000 per lot ($400,000 in total).

    Analysis:

    Company A should allocate the common costs ($100,000) and land cost ($320,000) based on the

    relative fair value of each parcel of land before construction. Each lot valued at $10,000 should be

    allocated $6,000 in costs ($10,000 individual value/$700,000 total value X $420,000 total costs)

    and each lot valued at $20,000 should be allocated $12,000 in costs ($20,000 individual

    value/$700,000 total value X $420,000 total costs).

    As noted above, whenever possible, costs should be allocated so that there is a consistent profit

    margin on the sale of individual units. If the lots were sold before construction of the homes, the sale

    of each lot would result in profit of $4,000 on the $10,000 lots and $8,000 on the $20,000 lots, for a

    consistent profit margin of 40 percent on all lots. In contrast, if each lot instead was allocated an equa

    share of the costs based on an area method (assuming all of the lots are the same size), each lot would

    be allocated $8,400 in costs and the sale of the $10,000 lots would result in a 16 percent profit

    margin, while the sale of the $20,000 lots would result in 58 percent margin.

    Although not specifically mentioned in the guidance for real estate project costs, we believe the above

    guidance primarily relates to real estate developed for sale versus real estate developed for rent.

    Because individual units in a rental project are not for sale, it is not generally necessary to allocate costs

    among the units. If allocation of capitalized costs is necessary (e.g., because the individual floors in an

    office building will not all be available for lease at the same time see Section 3.3), an area method

    should be used to allocate costs. This allocation will generally be limited to land and project costs, such a

    the overall cost of the building. The cost of an amenity should be capitalized as a separate asset and

    depreciation of the asset should commence when the amenity is substantially complete and available fo

    use (see Section 2.4 for additional information on accounting for amenities).

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